SCOPING REPORT. Moapa Solar Energy Center Environmental Impact Statement. Prepared for:

Transcription

1 Envirnmental Impact Statement SCOPING REPORT Prepared fr: Bureau f Indian Affairs Western Reginal Office 2600 Nrth Central Avenue Phenix, AZ and Bureau f Indian Affairs Suthern Paiute Agency P.O. Bx 720 St. Gerge, UT 84771

2 TABLE OF CONTENTS 1.0 INTRODUCTION PROJECT DESCRIPTION SCOPING PROCESS AND SOLICITATION OF COMMENTS FEDERAL REGISTER PROJECT WEBSITE SCOPING NOTIFICATION LETTER NEWSPAPER ADVERTISEMENTS METHODS FOR SUBMITTING COMMENTS PUBLIC SCOPING MEETINGS HAND-OUTS PRESENTATION INFORMATION STATIONS COMMENT EVALUATION COMMENTS RECEIVED PROCESSING COMMENTS SUMMARIZATION COMMENT RESULTS PER RESOURCE TOPIC PURPOSE AND NEED ALTERNATIVES CLIMATE WATER RESOURCES AIR QUALITY BIOLOGICAL RESOURCES SOCIOECONOMICS LAND/RESOURCE USE/VEGETATION CULTURAL RESOURCES VISUAL RESOURCES HEALTH AND SAFETY CUMULATIVE OTHER

3 6.0 ISSUE SUMMARY PURPOSE AND NEED ALTERNATIVES SENSITIVE WILDLIFE AND HABITATS VEGETATION WATER RESOURCE CLIMATE CHANGE AIR QUALITY SOCIOECONOMICS LAND/RESOURCE USE VISUAL RESOURCES CUMULATIVE IMPACTS NEXT STEPS APPENDICES APPENDIX A NOTICE OF INTENT APPENDIX B SCOPING NOTIFICATIONS APPENDIX C MEETING MATERIALS APPENDIX D CODING CATEGORIES APPENDIX E COMMENTS RECEIVED

4 1.0 INTRODUCTION The Bureau f Indian Affairs (BIA) is the lead Federal agency respnsible fr the Natinal Envirnmental Plicy Act (NEPA) prcess fr the prpsed (Prject). The BIA, in cperatin with the Mapa Band f Paiute Indians (Tribe), the Bureau f Land Management (BLM), the U.S. Envirnmental Prtectin Agency (EPA), the Natinal Park Service (NPS) and the U.S. Fish and Wildlife Service (USFWS), as cperating agencies, intends t prepare an envirnmental impact statement (EIS) fr the prpsed n the Mapa River Indian Reservatin (Reservatin) in Clark Cunty, Nevada. The purpse f this reprt is t summarize issue areas raised by individuals, rganizatins and agencies during the scping cmment perid fr this prject. This reprt summarizes all cmments received during the scping perid. The BIA will fully analyze the issues raised by these scping cmments and help shape the envirnmental analysis and alternatives t be cnsidered in the draft EIS. The NEPA scping prcess is designed t encurage invlvement by all interested parties and t help agencies make better infrmed decisins. This reprt als describes methds used fr sliciting input, as well as hw cmments received were categrized by resurce tpic. A cpy f each individual cmment received is cntained in Appendix E f this reprt. PROJECT DESCRIPTION The Prject wuld be lcated in Munt Diabl Meridian, Twnship 16 Suth, Range 64 East, Sectins 30 and 31, Clark Cunty, Nevada. Fr the purpses f this EIS, the Analysis Area will include an apprximately 1,000-acre slar site and water pipeline entirely lcated n the Reservatin. Crridrs fr the transmissin intercnnectin and access rad wuld be lcated n Federal lands managed by the BLM. The Prject may include tw slar technlgies. One wuld be a phtvltaic (PV) slar prject capable f prducing up t 100 megawatts (MW) f pwer. The PV prject wuld include up t 175,000 PV panels n single-axis tracking systems, inverters, and an peratin and maintenance building. Cnstructin f the PV slar cmpnent is expected t take up t 12 mnths and is prjected t have a life f 25 years. The secnd slar technlgy wuld be a cncentrating slar pwer (CSP) prject utilizing either eslar s CSP plant technlgy r AREVA Slar s CSP technlgy. The eslar technlgy cnsists f multiple 250- ft tall twer/receiver cmbinatins situated between fields f helistat mirrrs. The fcused slar heat bils water within the thermal receiver and prduces steam that is aggregated and sent t a steam turbine t generate electricity. AREVA Slar s Cmpact Linear Fresnel Reflectr uses mdular flat reflectrs t fcus the sun's heat nt elevated receivers which cnsist f a system f tubes thrugh which water flws. The cncentrated sunlight bils the water in the tubes (at an apprximate height f 80 feet) generating high-pressure superheated steam fr direct use in pwer generatin withut the need fr heat exchangers.

5 Page 1-2 The water supply required fr the CSP prject wuld be supplied by water leased frm the Tribe and delivered t the site via a water pipeline frm ne f the Tribe s prductin wells. The pipeline will be lcated entirely n the reservatin and will fllw existing rights-f-way. Other majr parts f the CSP prject wuld include an peratin and maintenance facility building alng with cling twers and evapratin pnds. The CSP prject is expected t take 24 mnths t cnstruct and expected t perate fr apprximately 25 t 30 years. An verhead 230 kilvlt (kv) transmissin line wuld cnnect the slar energy center t the nearby Harry Allen 230 kv Substatin apprximately six miles frm the site. An additinal 500 kv intercnnectin line culd be cnstructed and cnnected t the Crystal Substatin lcated apprximately ne mile east f prject bundary. An access rad wuld be cnstructed t the Prject site t prvide access frm the frntage rad alng the west side f Interstate-15 (I-15). This rad wuld be apprximately 2.5 miles lng and fllws existing rads fr much f its length.

6 2.0 SCOPING PROCESS AND SOLICITATION OF COMMENTS During the scping perid, the BIA infrmed the public, landwners, Gvernment agencies, tribes and interested stakehlders abut the prpsed and slicited their cmments. The BIA annunced the prject and scping prcess thrugh varius means, held public scping meetings, and invited the public t cmment and ask questins. The prject and public scping meetings were publicized in the Federal Register, n the prject website: in letters mailed t interested stakehlders, and thrugh public ntices/news releases published in lcal newspapers. These utreach and ntificatin activities are described in mre detail in the fllwing subsectins. FEDERAL REGISTER The public scping perid fficially began with the publicatin f the Ntice f Intent (NOI) t prepare an EIS which described the prject, annunced the public scping meetings, and utlined the ways t prvide cmments fr the. The NOI was published in the Federal Register n August 6, The NOI can be fund in Appendix A. PROJECT WEBSITE A prject website was established fr access by anyne at any time during the EIS prcess. It prvides prject infrmatin and an pprtunity t submit cmments. The website will remain active fr the duratin f the EIS prcess and can be accessed at SCOPING NOTIFICATION LETTER Scping ntificatin letters were sent by the BIA t Gvernment agencies, elected fficials, prperty wners near the prpsed prject, varius nn Gvernmental rganizatins and ther interested stakehlders. The scping letter briefly explained the prject, identified the Federal review prcess, annunced the public scping meetings, and described the varius ways t prvide cmments. Included with the scping ntificatin letter were prject area and prject lcatin maps. Over 75 scping letters were mailed n August 7, The scping letter with attached maps and the prject mailing list can be fund in Appendix B. NEWSPAPER ADVERTISEMENTS A public ntice/news release was published in three lcal newspapers n August 8, The publicatins included: Las Vegas Review Jurnal Las Vegas Sun Mapa Valley Prgress

7 Cpies f the published public ntice/news release can be viewed in Appendix B. Page 2-2 METHODS FOR SUBMITTING COMMENTS The BIA encuraged interested parties t submit cmments thrugh a variety f methds: Individual letters culd be hand delivered r mailed via the U.S. Pstal Service t Mr. Paul Schlafly, Natural Resurce Specialist, BIA, Suthern Paiute Agency, 180 Nrth 200 East Suite 111, P.O. Bx 720, St Gerge, Utah, 84770; r t Ms. Amy Heuslein, Reginal Envirnmental Prtectin Officer, BIA Western Reginal Office, 2600 Nrth Central Avenue, 4 th Flr Mailrm, Phenix, AZ Cmments culd be submitted via submit cmment tab n the prject website at Cmments culd be prvided via r phne t either Mr. Paul Schlafly, at paul.schlafly@bia.gv; telephne: (435) r Ms. Amy Heuslein, at amy.heuslein@bia.gv; telephne: (602) Cmments culd be prvided at the public meetings either rally r by filling ut a cmment frm prvided at the meetings (that culd be handed in at the meeting r mailed in at a later date). A cpy f the cmment frm is prvided in Appendix C. See belw fr the details f the scping meetings.

8 3.0 PUBLIC SCOPING MEETINGS The BIA hsted public infrmatin and scping meetings in Mapa Twn n the reservatin and in Las Vegas at the BLM ffice t prvide NEPA prcess and prpsed prject infrmatin and gather public cmments. The tw public scping meetings were held at the times and lcatins listed belw. Meeting Date and Time City/State/Zip Cde Address Attendance August 21, 2012 Mapa Twn, NV Mapa River Indian 40 5:30PM t 7:30PM Reservatin Tribal Hall, One Lincln Street August 22, 2012 Las Vegas, NV BLM Cnference Rm, 29 5:30PM t 7:30PM Suthern Nevada District Office, 4701 Nrth Trrey Pines Drive TOTAL ATTENDANCE 69 The public scping meetings were a cmbinatin f pen huse and frmal presentatin. Attendees were greeted at the entrance and asked t sign in. Handuts were available fr the public and psters were n display that described the prject and NEPA prcess. Attendees were able t ask questins t the agency and prject representatives while viewing psters. HAND-OUTS The fllwing handuts were available at the public meetings: 8 1/2 by 11 clr prject area map Public scping letter Cmment frm The handuts available at meetings can be fund in Appendix C. PRESENTATION Fllwing an pen huse f apprximately 30 minutes, a frmal presentatin was prvided. Bth scping meetings fllwed the same agenda, with the exceptin f an pening prayer that was cnducted at the Mapa River Indian Reservatin by Mr. Lery Sptted Eagle and intrductry remarks at the BLM ffice in Las Vegas by Ms. Brenda Wilhight, BLM Realty Specialist. The prgram pened with Chairman Mr. William Andersn f the Mapa Band f Paiute Indians prviding a brief histry f the Reservatin, what he envisins will be the future f his peple and the imprtance f the Prpsed Actin t the cmmunity f Paiute Indians. Ms. Kellie Yungbear, BIA Superintendant fr the Suthern Paiute Agency, intrduced herself and her agency staff. Fllwing Ms. Yungbear, Ms. Amy Heuslein, BIA Reginal Envirnmental Prtectin Officer, intrduced BIA and BLM staff and explained the varius ways t prvide cmments.

9 Page 3-2 Ms. Heuslein gave a presentatin explaining the purpse and need f the EIS, EIS schedule and the NEPA prcess. Mr. Randy Schreder f the EIS cnsultant team then presented the Prpsed Actin with an verview f the technical aspects and the envirnmental issues already identified t be addressed in the Draft EIS. Fllwing the presentatin, the attendees were invited t prvide verbal cmments r ask questins abut the Prpsed Actin. A curt reprter was present at the Mapa meeting and detailed ntes were taken at the Las Vegas meeting t recrd the public cmments expressed. The scping meeting presentatin, transcripts and public meeting summaries are prvided in Appendix C INFORMATION STATIONS Bth public meetings included the fllwing psters/ statins: Hw t Participate Areva Slar CSP Technlgy Prpsed Actin eslar CSP Technlgy NEPA Prcess/Schedule Phtvltaic Technlgy Invlved Agencies Assciated Prject Facilities Overall Prject Descriptin PV Slar Prject Cnceptual Site Layut Display bards presented at these statins are included in Appendix E. CSP and PV Slar Prject Cnceptual Site Layut

10 4.0 COMMENT EVALUATION COMMENTS RECEIVED The scping perid began n August 6, 2012, the date the NOI was published in the Federal Register. In additin t cmments received at the tw scping meetings there were 12 cmment letters/frms received thrugh a variety f means (see Methds fr Submitting Cmments fr mre details). All cmments were reviewed and categrized. Cpies f all cmments and their categrizatin are cntained in Appendix E. PROCESSING COMMENTS Each cmment letter was read t identify key issues and cde them. Cmmenter cntact infrmatin and cded cmments were recrded. In sme cases, a single cmment dcument cntained multiple cmments that were identified using a cding system that crrespnded t resurce/issue categries. Appendix D cntains the cding categries used. SUMMARIZATION This reprt summarizes issue areas identified frm the scping cmments received. Fr the purpses f this summary, all cmments were given equal weight, regardless f whether they were mentined nce r mentined several times. This reprt des nt priritize issue areas r track the number f cmments each issue categry received. The identified issues and areas f cncern will be used t guide the envirnmental analysis fr the EIS.

11 5.0 COMMENT RESULTS PER RESOURCE TOPIC The fllwing sectins rganize the cmments received by resurce and issue categries. Each cded individual cmment letter/frm shwing the individual cmments is shwn in Appendix E. PURPOSE AND NEED Prject shuld nt mve frward unless a better substantiatin f purpse f need is prvided. Given that the pwer frm the nearby K Rad Mapa facility has yet t be purchased, the public statements frm Nevada Energy that they are nt interested in purchasing any mre renewable energy at this time, and statements frm Califrnia that they nly want t purchase frm in state resurces, the entire purpse and need fr this prject is in dubt. When is the PPA ging t be in place? The prject sunds speculative. ALTERNATIVES Cnsider assessing a hybrid-wet/dry cling and dry-cling alternatives when deciding n technlgy. Include the exact number f CSP twers prpsed t be built. Include a cst/benefit analysis in the alternatives evaluatin. Explain why tw alternatives are being cnsidered and analyzed, but nly ne transmissin line will be built. Alternatives t dredge r fill materials discharged int the waters f the U.S. shuld be discussed. Since impacts n bilgical resurces vary between the different slar energy technlgies, recmmend determining the technlgy prir t the ROD t avid impacts t bilgical resurces. A range f meaningful alternatives shuld be explred. Cnsider alternatives t avid desert trtise habitat. CLIMATE Address additive impacts frm climate change n resurces affected by the prject, including impacts that the prject will have n desert trtise habitat and habitat linkages, carbn sequestratin frm the lss f desert vegetatin and sil disruptin.

12 Identify in the planning dcuments measures t avid significant adverse impacts that will change the landscape and negatively add t climate change. Page 5-2 Dcument the significant benefits frm reduced greenhuse gas emissins frm the prpsed prject as it cmpares t energy prductin assciated with fssil fuels. WATER RESOURCES Hw much grundwater is required fr PV and CSP? Where wuld the water be drawn frm the river r a well? Minimize water use ver prject life. Avid placement f helistats in desert washes. Cmmit t use natural washes fr fld cntrl. Cncern regarding impacts f grundwater usage. Cnsider benefits f PV technlgy with regard t water cnservatin. Effects f evapratin pnds assciated with CSP need t be evaluated. Identify quantity f water required during cnstructin and peratin prcess, describe surce f water, effects n ther users, impacts t grundwater recharge, and ther water bdies and bilgical resurces. Discuss ptential fr subsidence. The ptential fr water recycling and use f xeric plants fr landscaping shuld be addressed. Discuss climate change effects n water quantity. Address effect f prject discharges n water quality. Water sustainability must be ne f the guiding principles fr siting slar energy develpment. Slar energy develpment shuld nt cntribute t exceeding the sustainable yield f the surface r grundwater surce t avid injury t special status species and their habitat. The prject may be subject t Nevada Divisin f Envirnmental Prtectin, Bureau f Water Pllutin Cntrl (BWPC) permitting assciated with any f its discharges including, but nt limited t well develpment, wastewater, DeMinimis, Undergrund Injectin Cntrl (UIC), and dmestic sewage discharges. Other entities wh may have interest in the water in the area [USFWS, Suthern Nevada Water Authrity (SNWA), Muddy Valley Irrigatin Cmpany (MVIC)] that culd have an issue dwn the rad regarding the amunt f water that is needed fr the prject.

13 Page 5-3 A stringent water usage plan and water mnitring plan shuld be incrprated in the planning dcuments t take int accunt future prjects that maybe be prpsed fr the area and have additinal water usage requirements. AIR QUALITY Prvide a detailed discussin f ambient air cnditins (baseline r existing cnditins), Natinal Ambient Air Quality Standards (NAAQS) and nnattainment areas, and ptential air quality impacts f the prject, including cumulative and indirect impacts fr each fully evaluated alternative. Mitigatin measures shuld include multiple techniques t cmbat ptential fugitive dust situatins that may ccur during bth prject cnstructin and peratin. Emissins shuld be estimated fr the cnstructin phase, as well as fr the peratinal phase frm maintenance activities and ancillary peratins. Cnstructin-related mitigatin measures shuld be discussed. BIOLOGICAL RESOURCES Desert Trtise Avid and minimize unavidable impacts t desert trtise habitat. Any prpsed translcatin f desert trtise must be accmpanied by specific mnitring r research t study the success f these effrts. Will the desert trtise need t be relcated r allwed t stay in the area? Authrizatin by the State f Nevada is required in additin t any Federal authrizatins fr relcatin/remval f desert trtises. It is increasingly difficult t find intact, high quality desert trtise habitat in private wnership that culd be purchased and cnserved t prvide sme mitigatin fr the lss f ther ccupied desert trtise habitat in the Nrtheastern Mjave Recvery Unit such as the lands prpsed fr this slar plant. Address whether as part f the preparatin f the site fr slar energy develpment, mass grading and leveling wuld be required, that wuld destry trtise habitat and render it unsuitable in perpetuity. Cncerned that even if mass grading were nt dne, the habitat wuld be significantly degraded. Cncern that the prpsed prject may increase new sites fr perches and nests fr the cmmn raven (Crvus cra), a knwn predatr f juvenile desert trtises. Recmmend nn-lattice structures be cnsidered fr pwer lines because they affrd less perching, rsting and nesting lcatins fr ravens. Address ptential impacts t Mjave desert trtise (Gpherus agassizii) and Mapa dace (Mapa criacea), and their habitats.

14 Cncern that the Mapa dace may be impacted by grundwater withdrawal required fr the prject. The USFWS s Bilgical Opinin shuld be included as an appendix t the EIS. Analysis f impacts and mitigatin n listed species shuld include: Page 5-4 Baseline cnditins f habitats and ppulatins f the cvered species. Clear descriptin f hw avidance, mitigatin, and cnservatin measures will prtect and encurage the recvery f the cvered species and their habitats in the prject area. Mnitring, reprting and adaptive management effrts t ensure species and habitat cnservatin effectiveness. Include maps and descriptin f all waters f U.S. ptentially affected by the alternatives. Demnstrate the alternatives cmpliance with the Clean Water Act 404(b)(1) guidelines. Recmmend analysis f pssible prject impacts t federally listed species, state-prtected species and migratry birds. Discuss ptential impacts f cnstructin, installatin, and maintenance activities n habitat and species. Discuss the impacts assciated with an increase f shade in the desert envirnment n vegetatin and species, and impacts assciated with cnstructing fences arund the prject site. Recmmend multi-year avian surveys. Practices that preserve vegetatin and habitat, minimize weed invasin, and prevent ersin shuld be incrprated int the prject. Describe hw the prject will meet the requirements f Executive Order and include an invasive plant management plan fr the mnitring and cntrl f nxius weeds. Include mitigatin measures fr desert trtise and ther wildlife cnsidered avian prey. Cnsider innvative cnstructin techniques that leave vegetatin and wildlife habitat in place under phtvltaic panels and helistats t reduce cnstructin and maintenance csts by minimizing water ersin, reducing airbrne dust, preventing weed invasin, and hastening reclamatin. Gila mnster is knwn t ccur within the gegraphic area, thus recmmend evaluatin f prject impacts t any existing ppulatins and suitable habitat fr this species.

15 Page 5-5 Cncern that prject-related activities culd facilitate the incursin and/r spread f nn-native, invasive plants. The spread f invasive species is knwn t alter fire eclgy f the Mjave Desert and increase wildfire frequency. Develp a vegetatin plan describing hw sensitive r state listed plants will be avided, salvaged, and made available fr restratin r cmpensated fr. Avidance f sensitive and state-listed plants shuld be taken int accunt when develping the prject ftprint and the layut f slar infrastructure shuld be sited and arranged t avid impacting such plants. Plant surveys shuld be cnducted fr state prtected cacti and yuccas, stick ringstem, Beaverdam breadrt, three-crner milkvetch, Las Vegas buckwheat, sticky buckwheat, rsy tw-tned penstemn and white bearpppy during spring flwering perids and any fund plant lcatins gespatially mapped. At least tw years f plant surveys shuld be cnducted t cnfirm the absence f the species and if fund t be present, prtective measures shuld be established t avid, minimize and mitigate impacts. Land clearing r ther surface disturbance assciated with the prpsed prject shuld be cnducted utside the avian breeding and nesting seasn which ccurs apprximately between March 1 and July 31. If this is nt feasible, it is recmmended that a qualified bilgist survey the area prir t land clearing. If burrwing wls are determined thrugh surveys t ccur within the prject, the prject shuld be designed t avid disturbing burrws that are used by wls. Cncerns abut the ptential impacts t raptrs, including eagles and ther migratry birds, frm lss f fraging habitat, transmissin line strikes and pwer twers. It is recmmended that preprject surveys be cnducted fr raptrs, including eagles, and ther migratry birds, and t develp a Bird and Bat Cnservatin Strategy and an Eagle Cnservatin Plan. Hles, gaps r hllw spaces in the prpsed facilities r structures shuld be clsed during cnstructin t prevent bird entry. When the Bilgical Assessment (BA) is prepared and BIA requests cnsultatin, the prject design r prpsed actin shuld be near final with a preferred alternative that includes a single ftprint, prpsed methds, and technlgies. SOCIOECONOMICS When will any prject-related jbs be available? Tribal Emplyment Rights requires availability f jbs fr Native Americans.

16 Page 5-6 Hw are independent cntractrs n Indian land selected t ensure cnstructin/inspectin is dne crrectly and Indian investments are prtected? Ensure the prject leads t training and emplyment pprtunities including the creatin f lngterm jbs in the electricity and natural resurces sectrs fr the Mapa Band f Paiute Indians. Care shuld be taken t prtect ther users f cmmn crridrs. LAND/RESOURCE USE/VEGETATION Will the new transmissin lines be lcated in existing transmissin crridrs? As utility crridr crssings are determined as part f the prpsed prject, enugh space shuld be identified t allw utility crridr crssings be as near t right angles as pssible t separate transmissin lines s interference is minimized and the pssibility f cnstructin damage is minimized. Military Use The prpsed prject is under the primary rute used by military aircraft t enter and exit the Nevada Test and Training Range (NTTR) frm Nellis Air Frce Base (NAFB). The NTTR is a pristine military testing and training labratry built n ver 70 years f scientific research supprting military intelligence, arms, and radar advancement thrugh the investment f an incalculable sum f Federal funding. The training and testing envirnment prvided by the NTTR cannt be replicated. NAFB currently cnducts apprximately 50,000 ver-flights per year in this area, which will increase t an estimated 63,000 flights fllwing the bed-dwn f F-35 Jint Strike Fighter aircraft n NAFB. The area is lcated within the navigatinal aid flight path fr appraching aircraft and is nrth f the cntrlled bailut area. Ptential damage t the array may ccur depending n the altitude and directin f the aircraft during an emergency ejectin. Obstacles in this area are highly incmpatible with flight peratins, and may present severe safety cncerns. Thermal bundaries: Certain slar technlgies release r emit extreme heat near and/r abve their develpment. The extreme heat may create a thermal bundary that requires aircraft t avid the area in rder t prevent aircraft buffeting, damage, r accidents. Further, heat-sensitive armament may create a severe safety hazard fr aircrew and grund-based persnnel in the area.

17 Page 5-7 Glint/Glare: Depending n technlgy design features utilized, reflective glint and glare may create a severe safety hazard t pilts and aircraft, (including majr frce exercises such as RED FLAG and Weapns Schl Missin Emplyment Phase). Cameras/security: Many slar technlgies require the use f cameras fr the targeting f mirrrs n slar cllectrs. The use f high definitin camera equipment in the regin may present a security cncern fr jint and allied aircraft test and training peratins. Wireless systems: Electrnic jamming n the NTTR is cnducted n a regular basis. It is unknwn hw military peratins culd impact wirelessly cntrlled mirrrs, r hw disturbing the mirrr alignment culd create a glare hazard t flight crews r navigatin. Current Air Frce regulatins require pilts t avid structures by 500 feet, s any technlgy rising abve grund level (including PV arrays and slar twers) will place new and/r further restrictins n military peratins in the area. Transmissin lines (individually r thrugh a cumulative effect) may create restrictins that adversely impact military testing and training capabilities depending n the lcatin and/r quantity. CULTURAL RESOURCES The prject lcatin is abut five miles west f the Cngressinally-designated alignment f the Old Spanish Natinal Histric Trail (NHT), c-administered by the NPS and BLM. Traditinal Cultural Prperties VISUAL RESOURCES Hw tall are the twers fr bth the PV and CSP? Hw tall are the transmissin line ples? Will the transmissin lines be lcated in existing transmissin crridrs? The cnstructin f pwer twers in the vicinity f the Old Spanish Trail NHT is a cncern fr the NPS, and a phtvltaic nly prject is preferred. Where CSP technlgy is used, smaller twers with a height limit f 80 feet tall wuld be preferable. The use f phtvltaic technlgy r smaller pwer twers wuld minimize adverse impacts t the visual resurces f the Old Spanish Trail NHT. NPS suggests the use f clr palliatives t camuflage the scarring that may ccur when cutting in new rads as a prject design feature.

18 HEALTH AND SAFETY Page 5-8 Address ptential direct, indirect, and cumulative impacts f waste generatin, including hazardus waste, frm prject cnstructin and peratin. Hw tall are the twers fr bth the PV and CSP? Hw tall are the transmissin line ples? The military will need latitude/lngitude and Mean Sea Level/Abve Grund Level (MSL/AGL) heights. Transmissin lines (individually r cumulatively) may create restrictins that adversely impact military testing and training capabilities depending n the lcatin and/r quantity. Alternative methds that minimize hazardus materials use shuld be evaluated. Multiple issues regarding ptential hazards t air navigatin were raised by the Air Frce (summarized under land use heading abve). Cncern ver the mitigatin f ptential electrical current negatively affecting pipelines causing crrsin issues. CUMULATIVE What will be the cumulative effects f the grundwater usage? The and BLM Slar Energy Zne (SEZ) prpsals wuld bth affect the desert trtise and ther desert plant and wildlife species, and are in the same verextended carbnate grund water flw system, thereby ptentially impacting the rare and imperiled species, including the Mapa dace and ther rare desert fish and spring snails fund in the Muddy River drainage. Describe the methdlgy used t assess cumulative impacts; the methdlgy develped jintly by EPA, the Federal Highway Administratin, and the Califrnia Department f Transprtatin is recmmended. Address cumulative impacts t water resurces and the desert trtise. Cumulative impacts shuld cnsider ther prjects prpsed by BLM in the desert suthwest. There is cncern ver the magnitude and severity f impacts frm large-scale, disparate prjects in this area which may have significant and unintended cnsequences n bilgical resurces. In particular, ptential widespread lss, degradatin, r fragmentatin f habitats due t direct, indirect, r cumulative effects f numerus large-scale renewable energy prjects likely places listed species at a lwer prbability f recvery and increased risk f extirpatins r extinctin. Need t cnsider the cumulative impacts the Mapa Slar prject will have, as well as K Rad and ther existing prjects in the area.

19 Where is the lcatin f the K Rad Slar prject in relatin t the prject? OTHER Page 5-9 In 2011, The Nevada State Legislature passed AB307 resulting in NRS thrugh and creating the Energy Planning and Cnservatin Fund, and the Fund fr Recvery f Csts. Disclse the chsen slar technlgy in the Draft EIS. What is the advantage f ne technlgy versus the ther PV r CSP? Hw much pwer is required t pump the water needed fr the slar panels? Hw much pwer will be generated and is it a certainty? Cnsider prcuring PV cmpnents frm a cmpany that minimizes envirnmental impacts during prductin. Are there plans fr supplemental pwer during the night? Where will the pwer g t.nevada r Califrnia?

20 6.0 ISSUE SUMMARY This sectin prvides a summary f the key issues identified by the cmments prvided during scping fr the Prject. These issues will be the fcus f the EIS analysis. PURPOSE AND NEED The Purpse and Need fr the prject needs t be well substantiated including the need t prvide ecnmic pprtunity fr the Tribe as well as meeting the renewable energy gals f the cuntry and regin. ALTERNATIVES A range f meaningful alternatives need t be develped including a dry-cling and hybrid wet/dry cling technlgy alternatives fr the CSP technlgy with a crrespnding cst/benefit analysis. SENSITIVE WILDLIFE AND HABITATS Habitat lss r degradatin and ther impacts t sensitive species must be evaluated. The desert trtise is the primary species f interest and the ptential effect f grundwater withdrawal n the Mapa dace was als identified. Other species f interest are the gila mnster, Burrwing Owls, Raptrs including Eagles and ther migratry birds. VEGETATION The evaluatin f vegetatin impacts must include the ptential effects n sensitive r prtected plant species as well as the ptential fr the prject t facilitate the intrductin r spread f weeds. WATER RESOURCE Ptential hydrlgy impacts f grundwater usage particularly assciated with the prpsed CSP slar technlgy must be evaluated. Prject variatins r mitigatins that wuld minimize water use ver the prject life need t be cnsidered. Ptential effects n water quantity must als be included. CLIMATE CHANGE The ptential impacts f the prject n climate change must be evaluated. AIR QUALITY An analysis f air quality impacts including estimates f emissins fr bth the cnstructin and peratinal phases needs t be cnducted fr each alternative.

21 SOCIOECONOMICS Page 6-2 The ptential sciecnmic effects f the prject particularly n tribal members need t be evaluated. This must include a descriptin f the training and emplyment available t the Mapa Band f Paiute Indians that wuld be prvided by the prject. LAND/RESOURCE USE The ptential impact f the prject n the executin f military training activities cnducted by Nellis Air Frce Base in the area must be addressed. In additin, the lcatin and land wnership f new transmissin lines, water lines and access rads must be clarified. VISUAL RESOURCES The visibility f the prject frm the Old Spanish Natinal Histric Trail must be assessed t determine the ptential impact t the trail. CUMULATIVE IMPACTS The cumulative effect f the prpsed prject when cmbined with ther prjects in the area, need t be evaluated including specific attentin t ptential impacts t grundwater and sensitive bilgical resurces. Waste and hazardus waste generatin and management fr the prject must be clarified.

22 7.0 NEXT STEPS The BIA will develp the draft EIS fcusing n the identified issues, evaluating a range f reasnable alternatives, assessing ptential impacts, and identifying pssible mitigatin measures. Once cmplete, the BIA will publicly circulate the draft EIS and hst a public cmment perid. During this perid, the BIA will ntify the public and hld public meetings. Public cmments n the draft EIS will be respnded t in the final EIS. The BIA is cmmitted t invlving the public in the NEPA prcess. The BIA anticipates prviding peridic status updates and publishing all prject dcuments n the prject website: